As Veterans Day approaches, on this 100th anniversary marking the end of World War I, our thoughts turn to honoring – and thanking – our nation's veterans for their service. Some veterans, of course, have paid the ultimate sacrifice.
In the past, as readers of this space know, I have written at this time about the history and meaning of Veterans Day and, broadly, why it is important that we honor, in different ways, our veterans.
This time, I'm going to write about a matter closer to home – that is, "closer to home" in the sense of more usual Free State Foundation communications policy fare. I want to call attention to the importance of the FCC's Lifeline program to veterans.
Lifeline is the program that subsidizes telecommunications service for eligible low-income persons. As I said in a recent post, "Lifeline Matters," for at least two decades, I've been a supporter of a properly-run Lifeline program as a "safety net" for low-income persons who otherwise might not be able to afford telecom services. By properly-run, I mean that it is appropriate – indeed, necessary – that the FCC implement measures to curtail waste, fraud, and abuse in the program.
Now, for our veterans. According to recent comments filed by TracFone Wireless, Inc., approximately 1.3 million veterans (12 percent of all Lifeline support beneficiaries) participate in the Lifeline program. I suspect that many readers will be surprised by the size of that number. I am.
But the reality is that veterans, just like all other Americans, often need a safety net too. And, sometimes, as a result of their service, veterans' needs for communications services are more acute than for the population at large.
As TracFone put in its comments:
The Lifeline program plays an essential role in connecting those veterans with opportunities and essential resources. Broadband access allows veterans to stay connected not only with healthcare professionals, 911 emergency services, housing and veteran support services, but also family and friends. It enables veterans to connect with current and future employers and pursue an online education.
TracFone has heard from veterans directly through the Lifeline Facts Campaign about how the Lifeline program has improved their lives. Veterans suffering from a traumatic brain injury, for example, explained how they depend upon their Lifeline connection and mobile device to receive phone calls and automatic reminders about upcoming doctor’s appointments and when to take medication. Other veterans emphasized how important connectivity is for veterans who return home with limited or no support systems, and that it is nearly impossible to obtain a job in the 21st Century without an email address and phone number.
There is no need to belabor the point. To its credit, the Commission has been attentive to the needs of veterans in other contexts. Here I just want to use the occasion of Veterans Day to urge the Commission to keep veterans in mind as it considers the impact of its various Lifeline proposals. In short, to the extent that the Commission acts in a way that generally imperils the Lifeline program, its actions may well impact the 1.3 million veterans in the program too.
In my comments filed in the Commission's Bridging the Digital Divide for Low Income Consumers proceeding in February 2018, I addressed two measures of concern relating to the continued sustainability of the Lifeline program.
Please refer to my comments for more detail, but in short:
- I contended that the Commission should not adopt the proposal to discontinue Lifeline support for service provided over non-facilities-based networks. I stated that "while promoting increased facilities investment is, most often, a worthwhile objective, the primary purpose of the Lifeline program is to promote the affordability of communications services for low-income persons." With resellers presently serving approximately 70% of Lifeline subscribers, I said "the reality today is that facilities-based providers currently are serving only a minority of Lifeline subscribers, so that discontinuing support for resellers would be very disruptive to the program."
- I also supported the proposal to allow providers to meet the minimum service standard through plans that provide subscribers with a particular number of “units” that can be used either for voice minutes or broadband service. I called the proposal "a pro-consumer choice, pro-empowerment, pro-market-oriented proposal worthy of adoption." This seems like a sensible way to give Lifeline customers, including veterans, more flexibility to decide how best to meet their own needs. There is no good reason to assume that Lifeline customers cannot determine themselves how to use the quantity of service available to them under their Lifeline plan.
- Indeed, the Commission ought to reexamine in their entirety the minimum standard regulations adopted in 2016 under the leadership of previous FCC Chairman Tom Wheeler. In their current form, the inflexibility of the mandated standards limiting consumer choice is inconsistent with market-oriented principles. And the mandated increases in the minimum service standard requirements in coming years, in effect diminishing subsidy support, likely will mean the service will become less affordable and limit program participation.